Case: Brown v. Ramsay

Complaint pursuant to 42 USC 1983 against Richard A. Ramsay. Filing fee $ 400.00 receipt number 113C-11206151, filed by Peter Sean Brown. (Attachments: # 1 Civil Cover Sheet, # 2 Summon(s))(Kacou, Amien) (Entered: 12/03/2018)

1 Civil Cover Sheet

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2 Summon(s)

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Clerks Notice of Judge Assignment to Chief Judge K. Michael Moore and Ch. Magistrate Judge Andrea M. Simonton. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Andrea M. Simonton is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent. Pro se (NON-PRISONER) litigants may receive Notices of Electronic Filings (NEFS) via email after filing a Consent by Pro Se Litigant (NON-PRISONER) to Receive Notices of Electronic Filing. The consent form is available under the forms section of our website. (lbc) (Entered: 12/03/2018)

Summons Issued as to Richard A. Ramsay. (lbc) (Entered: 12/03/2018)

PAPERLESS PRETRIAL ORDER. This order has been entered upon the filing of the complaint. Plaintiff's counsel is hereby ORDERED to forward to all defendants, upon receipt of a responsive pleading, a copy of this Order. It is further ORDERED that S.D. Fla. L.R. 16.1 shall apply to this case and the parties shall hold a scheduling conference no later than twenty (20) days after the filing of the first responsive pleading by the last responding defendant, or within sixty (60) days after the filing of the complaint, whichever occurs first. However, if all defendants have not been served by the expiration of this deadline, Plaintiff shall move for an enlargement of time to hold the scheduling conference, not to exceed 90 days from the filing of the Complaint. Within ten (10) days of the scheduling conference, counsel shall file a joint scheduling report. Failure of counsel to file a joint scheduling report within the deadlines set forth above may result in dismissal, default, and the imposition of other sanctions including attorney's fees and costs. The parties should note that the time period for filing a joint scheduling report is not tolled by the filing of any other pleading, such as an amended complaint or Rule 12 motion. The scheduling conference may be held via telephone. At the conference, the parties shall comply with the following agenda that the Court adopts from S.D. Fla. L.R. 16.1: (1) Documents (S.D. Fla. L.R. 16.1.B.1 and 2) - The parties shall determine the procedure for exchanging a copy of, or a description by category and location of, all documents and other evidence that is reasonably available and that a party expects to offer or may offer if the need arises. Fed. R. Civ. P. 26(a)(1)(B). (a) Documents include computations of the nature and extent of any category of damages claimed by the disclosing party unless the computations are privileged or otherwise protected from disclosure. Fed. R. Civ. P. 26(a)(1)(C). (b) Documents include insurance agreements which may be at issue with the satisfaction of the judgment. Fed. R. Civ. P. 26(a)(1)(D). (2) List of Witnesses - The parties shall exchange the name, address and telephone number of each individual known to have knowledge of the facts supporting the material allegations of the pleading filed by the party. Fed. R. Civ. P. 26(a)(1)(A). The parties have a continuing obligation to disclose this information. (3) Discussions and Deadlines (S.D. Fla. L.R. 16.1.B.2) - The parties shall discuss the nature and basis of their claims and defenses and the possibilities for a prompt settlement or resolution of the case. Failure to comply with this Order or to exchange the information listed above may result in sanctions and/or the exclusion of documents or witnesses at the time of trial. S.D. Fla. L.R. 16.1.I. Pursuant to Administrative Order 2016-70 of the Southern District of Florida and consistent with the Court of Appeals for the Eleventh Circuits Local Rules and Internal Operating Procedures, within three days of the conclusion of a trial or other proceeding, parties must file via CM/ECF electronic versions of documentary exhibits admitted into evidence, including photographs of non-documentary physical exhibits. The Parties are directed to comply with each of the requirements set forth in Administrative Order 2016-70 unless directed otherwise by the Court.Telephonic appearances are not permitted for any purpose. Upon reaching a settlement in this matter the parties are instructed to notify the Court by telephone and to file a Notice of Settlement within twenty-four (24) hours. Signed by Chief Judge K. Michael Moore on 12/3/2018. (osk) (Entered: 12/03/2018)

PAPERLESS ORDER REFERRING PRETRIAL DISCOVERY MATTERS TO CHIEF MAGISTRATE JUDGE ANDREA M. SIMONTON. PURSUANT to 28 U.S.C. § 636 and the Magistrate Rules of the Local Rules of the Southern District of Florida, the above-captioned Cause is referred to United States Magistrate Judge Andrea M. Simonton to take all necessary and proper action as required by law with respect to any and all pretrial discovery matters. Any motion affecting deadlines set by the Court's Scheduling Order is excluded from this referral, unless specifically referred by separate Order. It is FURTHER ORDERED that the parties shall comply with Magistrate Judge Andrea M. Simonton's discovery procedures, which can be found on the Southern District of Florida website, www.flsd.uscourts.gov, under the tab for Judge Simonton, in the drop down menu Judge Information. Signed by Chief Judge K. Michael Moore on 12/3/2018. (osk) (Entered: 12/03/2018)

Notice of Pending, Refiled, Related or Similar Actions by Peter Sean Brown (Kacou, Amien) (Entered: 12/03/2018)

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Spencer Amdur. Filing Fee $ 75.00 Receipt # 113C-11219470 by Peter Sean Brown. Responses due by 12/20/2018 (Attachments: # 1 Certification Rule 4(b), # 2 Text of Proposed Order)(Kacou, Amien) (Entered: 12/06/2018)

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Cody Wofsy. Filing Fee $ 75.00 Receipt # 113C-11219518 by Peter Sean Brown. Responses due by 12/20/2018 (Attachments: # 1 Certification Rule 4(b), # 2 Text of Proposed Order)(Kacou, Amien) (Entered: 12/06/2018)

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Omar Jadwat. Filing Fee $ 75.00 Receipt # 113C-11219560 by Peter Sean Brown. Responses due by 12/20/2018 (Attachments: # 1 Certification Rule 4(b), # 2 Text of Proposed Order)(Kacou, Amien) (Entered: 12/06/2018)

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Lee Gelernt. Filing Fee $ 75.00 Receipt # 113C-11219602 by Peter Sean Brown. Responses due by 12/20/2018 (Attachments: # 1 Certification Rule 4(b), # 2 Text of Proposed Order)(Kacou, Amien) (Entered: 12/06/2018)

PAPERLESS ORDER. THIS CAUSE came before the Court upon the Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. 7 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is ORDERED AND ADJUDGED that the Motion 27 is GRANTED. Spencer Amdur may appear pro hac vice in this matter. The Clerk of Court shall provide electronic notification of all electronic filings to samdur@aclu.org. Signed by Chief Judge K. Michael Moore on 12/7/2018. (osk) (Entered: 12/07/2018)

PAPERLESS ORDER. THIS CAUSE came before the Court upon the Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. 8 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is ORDERED AND ADJUDGED that the Motion 27 is GRANTED. Cody Wofsy may appear pro hac vice in this matter. The Clerk of Court shall provide electronic notification of all electronic filings to cwofsy@aclu.org. Signed by Chief Judge K. Michael Moore on 12/7/2018. (osk) (Entered: 12/07/2018)

PAPERLESS ORDER. THIS CAUSE came before the Court upon the Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. 9 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is ORDERED AND ADJUDGED that the Motion 27 is GRANTED. Omar Jadwat may appear pro hac vice in this matter. The Clerk of Court shall provide electronic notification of all electronic filings to ojadwat@aclu.org. Signed by Chief Judge K. Michael Moore on 12/7/2018. (osk) (Entered: 12/07/2018)

PAPERLESS ORDER. THIS CAUSE came before the Court upon the Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. 10 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is ORDERED AND ADJUDGED that the Motion 27 is GRANTED. Lee Gelernt may appear pro hac vice in this matter. The Clerk of Court shall provide electronic notification of all electronic filings to lgelernt@aclu.org. Signed by Chief Judge K. Michael Moore on 12/7/2018. (osk) (Entered: 12/07/2018)

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Avi Garbow. Filing Fee $ 75.00 Receipt # 113C-11223920 by Peter Sean Brown. Responses due by 12/21/2018 (Attachments: # 1 Certification Rule 4(b), # 2 Text of Proposed Order)(Kacou, Amien) (Entered: 12/07/2018)

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Jonathan Soleimani. Filing Fee $ 75.00 Receipt # 113C-11223974 by Peter Sean Brown. Responses due by 12/21/2018 (Attachments: # 1 Certification Rule 4(b), # 2 Text of Proposed Order)(Kacou, Amien) (Entered: 12/07/2018)

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Jason Kim. Filing Fee $ 75.00 Receipt # 113C-11223983 by Peter Sean Brown. Responses due by 12/21/2018 (Attachments: # 1 Certification Rule 4(b), # 2 Text of Proposed Order)(Kacou, Amien) (Entered: 12/07/2018)

PAPERLESS PRETRIAL ORDER. This order has been entered upon the filing of the complaint. Plaintiff's counsel is hereby ORDERED to forward to all defendants, upon receipt of a responsive pleading, a copy of this Order. It is further ORDERED that S.D. Fla. L.R. 16.1 shall apply to this case and the parties shall hold a scheduling conference no later than twenty (20) days after the filing of the first responsive pleading by the last responding defendant, or within sixty (60) days after the filing of the complaint, whichever occurs first. However, if all defendants have not been served by the expiration of this deadline, Plaintiff shall move for an enlargement of time to hold the scheduling conference, not to exceed 90 days from the filing of the Complaint. Within ten (10) days of the scheduling conference, counsel shall file a joint scheduling report. Failure of counsel to file a joint scheduling report within the deadlines set forth above may result in dismissal, default, and the imposition of other sanctions including attorney's fees and costs. The parties should note that the time period for filing a joint scheduling report is not tolled by the filing of any other pleading, such as an amended complaint or Rule 12 motion. The scheduling conference may be held via telephone. At the conference, the parties shall comply with the following agenda that the Court adopts from S.D. Fla. L.R. 16.1: (1) Documents (S.D. Fla. L.R. 16.1.B.1 and 2) - The parties shall determine the procedure for exchanging a copy of, or a description by category and location of, all documents and other evidence that is reasonably available and that a party expects to offer or may offer if the need arises. Fed. R. Civ. P. 26(a)(1)(B). (a) Documents include computations of the nature and extent of any category of damages claimed by the disclosing party unless the computations are privileged or otherwise protected from disclosure. Fed. R. Civ. P. 26(a)(1)(C). (b) Documents include insurance agreements which may be at issue with the satisfaction of the judgment. Fed. R. Civ. P. 26(a)(1)(D). (2) List of Witnesses - The parties shall exchange the name, address and telephone number of each individual known to have knowledge of the facts supporting the material allegations of the pleading filed by the party. Fed. R. Civ. P. 26(a)(1)(A). The parties have a continuing obligation to disclose this information. (3) Discussions and Deadlines (S.D. Fla. L.R. 16.1.B.2) - The parties shall discuss the nature and basis of their claims and defenses and the possibilities for a prompt settlement or resolution of the case. Failure to comply with this Order or to exchange the information listed above may result in sanctions and/or the exclusion of documents or witnesses at the time of trial. S.D. Fla. L.R. 16.1.I. Pursuant to Administrative Order 2016-70 of the Southern District of Florida and consistent with the Court of Appeals for the Eleventh Circuits Local Rules and Internal Operating Procedures, within three days of the conclusion of a trial or other proceeding, parties must file via CM/ECF electronic versions of documentary exhibits admitted into evidence, including photographs of non-documentary physical exhibits. The Parties are directed to comply with each of the requirements set forth in Administrative Order 2016-70 unless directed otherwise by the Court.Telephonic appearances are not permitted for any purpose. Upon reaching a settlement in this matter the parties are instructed to notify the Court by telephone and to file a Notice of Settlement within twenty-four (24) hours. Signed by Chief Judge K. Michael Moore on 12/8/2018. (osk) (Entered: 12/08/2018)

PAPERLESS ORDER REFERRING PRETRIAL DISCOVERY MATTERS TO CHIEF MAGISTRATE JUDGE ANDREA M. SIMONTON. PURSUANT to 28 U.S.C. § 636 and the Magistrate Rules of the Local Rules of the Southern District of Florida, the above-captioned Cause is referred to United States Magistrate Judge Andrea M. Simonton to take all necessary and proper action as required by law with respect to any and all pretrial discovery matters. Any motion affecting deadlines set by the Court's Scheduling Order is excluded from this referral, unless specifically referred by separate Order. It is FURTHER ORDERED that the parties shall comply with Magistrate Judge Andrea M. Simonton's discovery procedures, which can be found on the Southern District of Florida website, www.flsd.uscourts.gov, under the tab for Judge Simonton, in the drop down menu Judge Information. Signed by Chief Judge K. Michael Moore on 12/8/2018. (osk) (Entered: 12/08/2018)

PAPERLESS ORDER. THIS CAUSE came before the Court upon the Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. 15 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is ORDERED AND ADJUDGED that the Motion 16 is GRANTED. Avi Garbow may appear pro hac vice in this matter. The Clerk of Court shall provide electronic notification of all electronic filings to agarbow@gibsondunn.com. Signed by Chief Judge K. Michael Moore on 12/8/2018. (osk) (Entered: 12/08/2018)

PAPERLESS ORDER. THIS CAUSE came before the Court upon the Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. 16 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is ORDERED AND ADJUDGED that the Motion 16 is GRANTED. Jonathan Soleimani may appear pro hac vice in this matter. The Clerk of Court shall provide electronic notification of all electronic filings to jsoleimani@gibsondunn.com. Signed by Chief Judge K. Michael Moore on 12/8/2018. (osk) (Entered: 12/08/2018)

PAPERLESS ORDER. THIS CAUSE came before the Court upon the Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. 17 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is ORDERED AND ADJUDGED that the Motion 17 is GRANTED. Jason Kim may appear pro hac vice in this matter. The Clerk of Court shall provide electronic notification of all electronic filings to jkim@gibsondunn.com. Signed by Chief Judge K. Michael Moore on 12/8/2018. (osk) (Entered: 12/08/2018)

SUMMONS (Affidavit) Returned Executed on 1 Complaint 42 USC 1983 or Bivens with a 21 day response/answer filing deadline by Peter Sean Brown. Richard A. Ramsay served on 12/4/2018, answer due 12/26/2018. (Kacou, Amien) (Entered: 12/08/2018)

NOTICE of Attorney Appearance by Bruce Wallace Jolly on behalf of Richard A. Ramsay. Attorney Bruce Wallace Jolly added to party Richard A. Ramsay(pty:dft). (Jolly, Bruce) (Entered: 12/11/2018)

ORDER TRANSFERRING CASE to Judge Kathleen M. Williams for all further proceedings, accepted and signed on 12/12/2018. Chief Judge K. Michael Moore no longer assigned to case Signed by Chief Judge K. Michael Moore on 12/12/2018. See attached document for full details. (cds) (Entered: 12/13/2018)

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Sarah M. Rich. Filing Fee $ 75.00 Receipt # 113C-11240312 by Peter Sean Brown. Responses due by 12/27/2018 (Bonilla Lopez, Viviana) (Entered: 12/13/2018)

PAPERLESS ORDER REFERRING 26 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Sarah M. Rich. Filing Fee $ 75.00 Receipt # 113C-11240312 filed by Peter Sean Brown. ORDER REFERRING CASE to Magistrate Judge Edwin G. Torres for Pretrial Non-Dispositive Matters. Ch. Magistrate Judge Andrea M. Simonton no longer assigned as referral judge in this case. Motions referred to Judge Edwin G. Torres. Signed by Judge Kathleen M. Williams on 12/14/2018. (jws) (Entered: 12/14/2018)

PAPERLESS ORDER granting 26 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney(s) Sarah M. Rich. The Clerk shall add pro hac counsel as co-counsel of record for Plaintiff. Signed by Magistrate Judge Edwin G. Torres on 12/14/2018. (EGT) (Entered: 12/14/2018)

MOTION for Extension of Time to File Response/Reply/Answer by Richard A. Ramsay. (Jolly, Bruce) (Entered: 12/20/2018)

PAPERLESS ORDER granting 29 Unopposed Motion for Extension of Time to File Response/Answer to Plaintiff's Complaint. Upon a review of the motion and for good cause shown, Defendant's motion is GRANTED. Defendant shall file a response to Plaintiff's complaint by January 2, 2019 and Plaintiff shall, if appropriate, file a response by January 23, 2019. Signed by Judge Kathleen M. Williams on 12/20/2018. (jws) (Entered: 12/20/2018)

ANSWER and Affirmative Defenses to Complaint with Jury Demand by Richard A. Ramsay. (Jolly, Bruce) (Entered: 01/02/2019)

ORDER. Responses due by 2/8/2019. Signed by Judge Kathleen M. Williams on 1/2/2019. See attached document for full details. (lbc) (Entered: 01/02/2019)

STATUS REPORT by Peter Sean Brown (Attachments: # 1 Supplement Jointly Proposed Schedule)(Kacou, Amien) (Entered: 02/08/2019)

SCHEDULING ORDER: Jury Trial set for 2/3/2020 in Miami Division before Judge Kathleen M. Williams. Calendar Call set for 1/28/2020 11:00 AM before Judge Kathleen M. Williams. Signed by Judge Kathleen M. Williams on 2/11/2019. See attached document for full details. (cds) Pattern Jury Instruction Builder - To access the latest, up to date changes to the 11th Circuit Pattern Jury Instructions go to https://pji.ca11.uscourts.gov or click here. (Entered: 02/11/2019)

Unopposed MOTION to Withdraw as Attorney by Avi Garbow for / by Peter Sean Brown. Responses due by 3/8/2019 (Attachments: # 1 Text of Proposed Order Proposed Order Granting Unopposed Motion to Withdraw as Counsel)(Kacou, Amien) (Entered: 02/22/2019)

PAPERLESS ORDER granting 35 Motion to Withdraw as Attorney. Avi Samuel Garbow withdrawn from case as counsel or Plaintiff who remains represented in the action through other counsel of record. Signed by Magistrate Judge Edwin G. Torres on 3/8/2019. (EGT) (Entered: 03/08/2019)

Order on Motion to Withdraw as Attorney

Request for Clerk to Appoint Mediator(Kacou, Amien) (Entered: 03/13/2019)

Clerk's Appointment of Mediator: Thomas D. Lardin added (pt) (Entered: 03/14/2019)

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Heather L. Richardson. Filing Fee $ 75.00 Receipt # 113C-11525551 by Peter Sean Brown. Responses due by 4/16/2019 (Attachments: # 1 Certification of H. Richardson in support of PHV Application, # 2 Text of Proposed Order Granting H. Richardson PHV Application)(Kacou, Amien) (Entered: 04/02/2019)

PAPERLESS ORDER granting 39 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney(s) Heather L. Richardson as co-counsel of record for Plaintiff. Signed by Magistrate Judge Edwin G. Torres on 4/3/2019. (EGT) (Entered: 04/03/2019)

(STRICKEN PER DE#42)NOTICE by Richard A. Ramsay of Taking Deposition (Plaintiff) (Jolly, Bruce)Text Modified on 4/4/2019 (cqs). (Entered: 04/03/2019)

PAPERLESS ORDER STRIKING 41 Notice (Other) of Deposition filed by Richard A. Ramsay. Defendant's notice of deposition is STRICKEN for failure to comply with the Local Rules for the Southern District of Florida. Local Rule 26.1 provides "[i]nitial and expert disclosures and the following discovery requests, responses, objections, notices or any associated proof of service shall not be filed until they are used in the proceeding or the court orders their filing: (1) deposition transcripts; (2) interrogatories; (3) requests for documents, electronically stored information or things, or to permit entry upon land; (4) requests for admission; (5) notices of taking depositions or notices of serving subpoenas; and (6) privilege logs. Going forward, failure to comply with the Local Rules, the Federal Rules of Civil Procedure, and this Court's policies and procedures may result in sanctions. Signed by Judge Kathleen M. Williams on 4/3/2019. (jws) (Entered: 04/03/2019)

PAPERLESS ORDER TO SHOW CAUSE. The Court's Scheduling Order 34 required that "[w]ithin thirty (30) days of the date of this Order, the Parties shall: select a mediator certified under Local Rule 16.2(b); schedule a time, date, and place for mediation; and jointly file a proposed order scheduling mediation." Although the Parties filed a joint motion for the Clerk to appoint a mediator and a mediator was appointed on March 14, 2019, the Parties have nonetheless failed to comply with this requirement. Accordingly, the Parties are ORDERED TO SHOW CAUSE by April 4, 2019 at 5:00 p.m. as to why sanctions should not be imposed for their failure to comply with Court order. Signed by Judge Kathleen M. Williams on 4/3/2019. (jws) (Entered: 04/03/2019)

Order on Motion to Appear Pro Hac Vice

Order to Show Cause

Order Striking

RESPONSE TO ORDER TO SHOW CAUSE re 43 Order to Show Cause,,, by Peter Sean Brown. (Attachments: # 1 Exhibit A - Notice of Filing Proposed Mediation Order, # 2 Text of Proposed Order Granting Joint Motion to File Out of Time Mediation Order)(Kacou, Amien) (Entered: 04/04/2019)

PAPERLESS ORDER SCHEDULING MEDIATION. A mediation conference in this matter shall be held with Thomas D. Lardin on August 21, 2019, at 10:00 a.m., at 401 E. Las Olas Blvd, Fort Lauderdale, Florida, 33301. This date shall not be rescheduled without leave of Court, which will not be granted absent a motion setting forth good cause. The parties are responsible for ensuring that within three business days of the mediation, a mediation report is filed, indicating whether the case settled (in full or in part), was continued with the consent of the parties, or whether the mediator declared an impasse. Signed by Judge Kathleen M. Williams on 4/4/2019. (jws) (Entered: 04/04/2019)

Order Scheduling Mediation

PAPERLESS NOTICE of Hearing: A Discovery Hearing is set for 5/10/2019 at 02:30 PM in Miami Division before Magistrate Judge Edwin G. Torres. (js02) (Entered: 04/17/2019)

PAPERLESS ORDER re [D.E. 46] Notice re Hearing:The discovery hearing previously set for 5/10/2019 is RESCHEDULED to 5/9/2019 at 2:30 p.m. The parties shall continue to comply with the requirements of the Order Setting Discovery Procedures with respect to submission of materials for that hearing by 5/6/2019. Signed by Magistrate Judge Edwin G. Torres on 4/17/2019. (EGT) (Entered: 04/17/2019)

- Order (PAPERLESS or pdf attached)

PAPERLESS NOTICE of Hearing: Discovery Hearing RESET for 5/7/2019 02:30 PM in Miami Division before Magistrate Judge Edwin G. Torres, James Lawrence King Federal Justice Building, 99 NE 4th Street, 10th Floor - Courtroom 5, Miami, FL 33132. (mdc) (Entered: 04/26/2019)

MOTION to Continue Hearing by Richard A. Ramsay. Responses due by 5/14/2019 (Jolly, Bruce) (Entered: 04/30/2019)

PAPERLESS ORDER granting 49 Motion to Continue Hearing, for good cause shown in the unopposed motion: Discovery Hearing re-set for 5/30/2019 11:00 AM in Miami Division before Magistrate Judge Edwin G. Torres. Compliance with submission of related materials due by 5/20/2019. Signed by Magistrate Judge Edwin G. Torres on 4/30/2019. (EGT) (Entered: 04/30/2019)

Order on Motion to Continue

NOTICE of Compliance re Discovery Hearing by Peter Sean Brown re 46 Notice re Hearing, 50 Order on Motion to Continue, (Kacou, Amien) (Entered: 05/20/2019)

Unopposed MOTION to Withdraw as Attorney by Nancy Gbana Abudu for / by Peter Sean Brown. Responses due by 6/3/2019 (Attachments: # 1 Text of Proposed Order Granting Unopposed Motion to Withdraw as Counsel)(Kacou, Amien) (Entered: 05/20/2019)

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Jennifer K. Bracht. Filing Fee $ 75.00 Receipt # 113C-11667685 by Peter Sean Brown. Responses due by 6/5/2019 (Attachments: # 1 Certification of Jennifer K. Bracht, # 2 Text of Proposed Order Granting Motion to Appear Pro Hac Vice)(Kacou, Amien) (Entered: 05/22/2019)

PAPERLESS NOTICE OF CANCELLATION OF HEARING: Hearing currently set for May 30, 2019 is hereby CANCELLED. (abu) (Entered: 05/28/2019)

PAPERLESS NOTICE of Hearing: The discovery hearing set for May 30, 2019 will now take place on June 13, 2019 at 3:30 P.M. The parties must still comply with the requirements found in this Court's standing Discovery Order. (abu) (Entered: 05/28/2019)

NOTICE of Attorney Appearance by Daniel Boaz Tilley on behalf of Peter Sean Brown. Attorney Daniel Boaz Tilley added to party Peter Sean Brown(pty:pla). (Tilley, Daniel) (Entered: 05/29/2019)

NOTICE by Richard A. Ramsay of Filing Answers to Interrogatories (Jolly, Bruce) (Entered: 05/30/2019)

PAPERLESS ORDER granting 52 Motion to Withdraw as Attorney. Nancy Gbana Abudu withdrawn from case as counsel for plaintiff who is separately represented by counsel in the action; granting 53 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney(s) Jennifer K. Bracht. The Clerk shall add pro hac counsel as counsel of record for Plaintiff. Signed by Magistrate Judge Edwin G. Torres on 5/31/2019. (EGT) (Entered: 05/31/2019)

Order on Motion to Appear Pro Hac Vice

Order on Motion to Withdraw as Attorney

NOTICE of Compliance re June 13 Discovery Hearing by Peter Sean Brown re 55 Notice re Hearing, (Kacou, Amien) (Entered: 06/10/2019)

MOTION to Take Deposition from Peter Sean Brown by Richard A. Ramsay. (Jolly, Bruce) (Entered: 06/11/2019)

PAPERLESS Minute Entry for proceedings held before Magistrate Judge Edwin G. Torres: Discovery Hearing HELD on 6/13/2019. Total time in court: 1 hour: 08 minutes. Attorney Appearance(s): Daniel Boaz Tilley, Jonathan N. Soleimani, Bruce Wallace Jolly, (Digital 15:44:41 - 16:53:13) (mdc) (Entered: 06/13/2019)

TRANSCRIPT of Discovery Hearing (Transcribed from the Digital Audio Recording) held on June 13, 2019, before Magistrate Judge Edwin G. Torres, 1-76 pages, Court Reporter: Lisa Edwards, 305-439-7168 / reporterlisaedwards@gmail.com. (Digital 15:44:41.) Transcript may be viewed at the court public terminal or purchased by contacting the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 7/9/2019. Redacted Transcript Deadline set for 7/19/2019. Release of Transcript Restriction set for 9/16/2019. (le) (Entered: 06/18/2019)

Corrected Transcript and Notice of Correction of the Discovery Hearing (Transcribed from the Digital Audio Recording) held on June 13, 2019, before Magistrate Judge Edwin G. Torres, 1-76 pages, re: 62 Transcript. Court Reporter: Lisa Edwards, 305-439-7168 / reporterlisaedwards@gmail.com. (le) (Entered: 06/20/2019)

PAPERLESS NOTICE of Hearing: A Discovery Hearing is set for 7/3/2019 at 10:30 AM in Miami Division before Magistrate Judge Edwin G. Torres. (js02) (Entered: 06/25/2019)

RESPONSE in Opposition re 60 MOTION to Take Deposition from Peter Sean Brown filed by Peter Sean Brown. Replies due by 7/2/2019. (Kacou, Amien) (Entered: 06/25/2019)

PAPERLESS NOTICE OF CANCELLATION OF HEARING: The Discovery Hearing set for 7/3/2019 at 10:30 AM is hereby CANCELLED. (abu) (Entered: 06/27/2019)

PAPERLESS NOTICE of Hearing: Discovery Hearing RESET for July 11, 2019 at 01:30 PM in the Miami Division before Magistrate Judge Edwin G. Torres. (abu) (Entered: 06/27/2019)

NOTICE of Compliance re July 11 Discovery Hearing by Peter Sean Brown re 67 Notice re Hearing (Kacou, Amien) (Entered: 07/08/2019)

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for PATRICK HAYDEN. Filing Fee $ 75.00 Receipt # 113C-11804961 by Peter Sean Brown. Responses due by 7/25/2019 (Attachments: # 1 Certification of Patrick Hayden, # 2 Text of Proposed Order)(Kacou, Amien) (Entered: 07/11/2019)

DISCOVERY ORDER: ORDER Granting Motion to Take Deposition of Confined Person. Signed by Magistrate Judge Edwin G. Torres on 7/11/2019. See attached document for full details. (EGT) (Entered: 07/11/2019)

PAPERLESS Minute Entry for proceedings held before Magistrate Judge Edwin G. Torres: Discovery Hearing held on 7/11/2019. Total time in court: 1 hour(s) : 1 minutes. Attorney Appearance(s): Daniel Boaz Tilley, Viviana Teresa Bonilla Lopez, Bruce Wallace Jolly, (Digital 13:36:56) (mdc) (Entered: 07/19/2019)

PAPERLESS ORDER granting 69 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. The Court finds that the application satisfies the requirements of S.D. Fla. Local Atty. R. 4. Therefore, the Clerk is directed to add Patrick Hayden, Esq. as counsel of record for Defendant and allow counsel to be noticed electronically on CM/ECF. Docket Order Signed by Magistrate Judge Edwin G. Torres on 7/17/2019. (abu) (Entered: 07/17/2019)

PAPERLESS ORDER granting 69 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Patrick Hayden. The Court finds that the application satisfies the requirements of S.D. Fla. Local Atty. R. 4. Therefore, the Clerk is directed to add Patrick Hayden, Esq. as counsel of record for Plaintiff and allow counsel to be noticed electronically on CM/ECF. Signed by Magistrate Judge Edwin G. Torres on 7/17/2019. (js02) (Entered: 07/17/2019)

Order on Motion to Appear Pro Hac Vice

Discovery Order re July 11, 2019 Hearing. Signed by Magistrate Judge Edwin G. Torres on 7/19/2019. See attached document for full details. (js02) (Entered: 07/19/2019)

PAPERLESS ORDER denying as moot 60 Motion to Take Deposition as an Order was already entered on 7/11/2019 for the requested deposition. Signed by Magistrate Judge Edwin G. Torres on 7/23/2019. (EGT) (Entered: 07/23/2019)

Unopposed MOTION to Continue Trial Date and Remaining Pretrial Deadlines re 34 Scheduling Order,, by Peter Sean Brown. Responses due by 8/6/2019 (Attachments: # 1 Text of Proposed Order Granting Unopposed Motion for Continuance of Trial and Remaining Pretrial Deadlines, # 2 Affidavit of Jonathan N. Soleimani in Support of Unopposed Motion for Continuance of Trial and Remaining Pretrial Deadlines, # 3 Exhibit A - Excerpts of Transcript from June 13, 2019 Discovery Hearing)(Kacou, Amien) (Entered: 07/23/2019)

Order on Motion to Take Deposition

AMENDED SCHEDULING ORDER: Granted In Part: 76 Unopposed MOTION to Continue Trial Date and Remaining Pretrial Deadlines re 34 Scheduling Order,, filed by Peter Sean Brown. ( Jury Trial set for 4/13/2020 in Miami Division before Judge Kathleen M. Williams., Calendar Call set for 4/7/2020 11:00 AM before Judge Kathleen M. Williams.), Signed by Judge Kathleen M. Williams on 7/24/2019. See attached document for full details. (cds) Pattern Jury Instruction Builder - To access the latest, up to date changes to the 11th Circuit Pattern Jury Instructions go to https://pji.ca11.uscourts.gov or click here. (Entered: 07/24/2019)

PAPERLESS NOTICE of Hearing: A Discovery Hearing is set for 8/2/2019 at 10:45 AM in Miami Division before Magistrate Judge Edwin G. Torres. (js02) (Entered: 07/29/2019)

PAPERLESS NOTICE of Hearing: **TIME AND DATE CHANGE** Discovery Hearing RESET for 8/16/2019 at 09:00 AM in Miami Division before Magistrate Judge Edwin G. Torres. (js02) (Entered: 07/29/2019)

Defendant's MOTION to Change Venue by Richard A. Ramsay. Responses due by 8/15/2019 (Jolly, Bruce) (Entered: 08/01/2019)

MOTION Motion to Dismiss for Plaintiff's Invocation of the Fifth Amendment Privilege During Deposition by Richard A. Ramsay. (Jolly, Bruce) (Entered: 08/01/2019)

NOTICE of Attorney Appearance by Harrison Adan Joss on behalf of Richard A. Ramsay. Attorney Harrison Adan Joss added to party Richard A. Ramsay(pty:dft). (Joss, Harrison) (Entered: 08/01/2019)

NOTICE of Compliance re August 16, 2019 Discovery Hearing by Peter Sean Brown re 79 Notice re Hearing (Kacou, Amien) (Entered: 08/11/2019)

Joint MOTION for Extension of Time to Mediate to September 3, 2019 by Peter Sean Brown. (Attachments: # 1 Affidavit of Jonathan N. Soleimani in support of Joint Motion to Continue Mediation Date, # 2 Text of Proposed Order Granting Joint Motion to Continue Mediation Date)(Kacou, Amien) (Entered: 08/13/2019)

NOTICE of Attorney Appearance by Anne Janet Hernandez Anderson on behalf of Peter Sean Brown. Attorney Anne Janet Hernandez Anderson added to party Peter Sean Brown(pty:pla). (Hernandez Anderson, Anne) (Entered: 08/13/2019)

PAPERLESS ORDER granting 84 Joint Motion for Extension of Time to Mediate. The Parties shall attend mediation on September 3, 2019, at 10:00 a.m. and shall file their mediation report on that date. Mediation Deadline 9/3/2019. Signed by Judge Kathleen M. Williams on 8/14/2019. (jws) (Entered: 08/14/2019)

Order on Motion for Extension of Time to Mediate

RESPONSE in Opposition re 80 Defendant's MOTION to Change Venue filed by Peter Sean Brown. Replies due by 8/22/2019. (Tilley, Daniel) (Entered: 08/15/2019)

RESPONSE in Opposition re 81 MOTION Motion to Dismiss for Plaintiff's Invocation of the Fifth Amendment Privilege During Deposition filed by Peter Sean Brown. Replies due by 8/22/2019. (Attachments: # 1 Declaration of J. Soleimani in support of Plaintiff's Opposition to Motion to Dismiss, # 2 Exhibit A - Transcript of Plaintiff's Deposition, # 3 Exhibit B - Dkt. 51 - 2019.05.20 - Notice of Compliance, # 4 Exhibit C - Dkt. 59 - 2019.06.10 - Amended Notice of Compliance, # 5 Exhibit D - Dkt. 68 - 2019.07.08 - Notice of Compliance, # 6 Exhibit E - Dkt. 83 - 2019.08.11 - Notice of Compliance, # 7 Exhibit F - 2019.04.09 - Plaintiff's Meet and Confer Email with Defendant Regarding Discovery, # 8 Exhibit G - 2019.04.16 - Plaintiff's Email re Lingering Disputes and Hearing with J. Torres, # 9 Exhibit H - 2019.06.26 - Plaintiff's Discovery Letter re Defendant's Failure to Comply with June 13 Bench Rulings, # 10 Exhibit I - Dkt. 74 - 2019.07.19 - Order Granting in Part Plaintiff's Motion to Compel, # 11 Exhibit J - 2019.07.23 - Plaintiff's Letter Regarding Productions and Responses Ordered by Court on July 11, 2019)(Tilley, Daniel) (Entered: 08/15/2019)